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You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Begin by explaining that the case has reached the discovery stage and what that means. Something like this: At this stage of the pending action, all parties are subject to procedures called ?discovery? that allow each party to obtain information and documents relevant to the case.
Rule 33(b), Federal Rules of Civil Procedure, requires the respondent to answer an interrogatory separately and fully in writing and under oath, unless the respondent objects, in which event the party objecting shall state with specificity the reasons for objection and shall answer to the extent the interrogatory is ...
Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection shall be stated in lieu of an answer. The answers are to be signed by the person making them, and the objections signed by the attorney making them.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
You have 30 days to respond to Form Interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond. In eviction (unlawful detainer) cases the time is much shorter. In eviction cases you have 5 days to respond, or typically 10 days from the date of mailing if served by mail.
You have to respond to interrogatories in writing to the best of your ability. If you do not answer an interrogatory question, and then the other side learns that you did in fact know the answer, it could have a negative impact on your case at trial.